In our joint submission with Financial Rights Legal Centre, Consumer Credit Legal Service (WA), Financial Counselling Australia and the Financial & Consumer Rights Council, we support Cameron Ralph Khoury’s Report Series approach to the Independent Review of the Customer Owned Banking Code of Practice (the Code). It appears to be a simple and transparent approach to collecting and responding to stakeholder feedback.
We strongly support the Report’s recommendation that the entire Code should be enforceable by customers as part of their customer contract with the customer owned bank, mutual bank or credit union.
The submission also comments on:
- Code style and structure;
- Key promises;
- Language and style;
- Small business provisions; and
- Initial drafting.